Commonwealth of Virginia v. Sean Earl Gittens

CourtCourt of Appeals of Virginia
DecidedFebruary 3, 2026
Docket1587251
StatusUnpublished

This text of Commonwealth of Virginia v. Sean Earl Gittens (Commonwealth of Virginia v. Sean Earl Gittens) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth of Virginia v. Sean Earl Gittens, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges AtLee, Friedman and Senior Judge Annunziata UNPUBLISHED

Argued by videoconference

COMMONWEALTH OF VIRGINIA MEMORANDUM OPINION* BY v. Record No. 1587-25-1 JUDGE RICHARD Y. ATLEE, JR. FEBRUARY 3, 2026 SEAN EARL GITTENS

FROM THE CIRCUIT COURT OF THE CITY OF VIRGINIA BEACH Salvatore R. Iaquinto, Judge

Andrew T. Hull, Assistant Attorney General (Jason S. Miyares,1 Attorney General, on briefs), for appellant.

James O. Broccoletti (S. Mario Lorello; Zoby & Broccoletti, P.C., on brief), for appellee.

A grand jury indicted Sean Earl Gittens of one count of possession of a firearm by a felon,

in violation of Code § 18.2-308.2, and one count of receipt of a stolen firearm, in violation of Code

§ 18.2-108.1. Gittens moved to suppress certain statements he made to law enforcement officers,

arguing that the statements were obtained in violation of his Fifth Amendment right to remain silent.

The trial court granted the motion to suppress. Pursuant to Code § 19.2-398, the Commonwealth

now appeals that ruling. The Commonwealth argues that Gittens reinitiated conversation with law

enforcement and thus waived his previously invoked right to silence. For the following reasons, we

disagree and affirm the trial court.

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. I. BACKGROUND

In a Commonwealth’s appeal of an order suppressing evidence, “the evidence must be

viewed in the light most favorable to the defendant,” the party who prevailed below.

Commonwealth v. Peterson, 15 Va. App. 486, 487 (1992).

As part of a narcotics investigation, the Chesterfield County Police Department executed

search warrants in various jurisdictions of the Commonwealth, including at Gittens’s residence

in Virginia Beach. During execution of the warrant, law enforcement officers detained Gittens,

bringing him outside and placing him in the front passenger seat of Detective Hopkins’s truck.

Initially, the truck was parked in the road in front of Gittens’s house. After the scene was

secured by the SWAT team, Hopkins moved the truck into Gittens’s driveway.

Hopkins advised Gittens of his Miranda2 rights before questioning him. Hopkins

questioned Gittens about his involvement with narcotics, and most of the interview occurred

while the truck was parked in the driveway. According to Hopkins, Gittens indicated his

willingness to speak with Hopkins “on multiple occasions” during the interview, which was

recorded.

Throughout the recording, however, Gittens expressed hesitation about speaking with

Hopkins at that time because he was concerned that somebody could be watching him. Gittens

indicated that he would be willing to speak with Hopkins later. Gittens offered to take Hopkins’s

number and call him, telling Hopkins, “I guarantee before you get down the block, I’ll probably

call you.” Gittens told Hopkins that he “kn[ew] some things that [Hopkins] would want to

know.” Hopkins then asked if Gittens knew people moving drugs, and Gittens responded, “What

do you think? Come on man. . . . I know people that do stuff like that.” When Hopkins asked if

Gittens wanted to talk to somebody about that, Gittens responded, “I’ll talk to you.” At this

2 Miranda v. Arizona, 384 U.S. 436 (1966). -2- point, approximately one hour and thirty minutes into the interaction, Hopkins asked Gittens,

“But you don’t want to talk right now?” Gittens answered, “No. You get what I’m saying?”

Hopkins got out of the truck as Gittens was still speaking.

Almost immediately after Hopkins got out of the truck, Officer Joy got in. As she got in,

Gittens said, “I know this is an everybody operation.” He then explained to her that he had told

Hopkins that “now is not the time” to have a conversation about “specifics.” He also explained

that he was concerned that people could be watching him. When Joy asked what would have

made it better for him, Gittens suggested that the detective could have given him a phone number

to call later or pulled him over to talk to him. Joy asked him if he had cooperated with police

before. They also discussed the clothing that he was wearing. Joy advised Gittens that the

detective was going to keep talking to him and told him to be honest when they speak.

Detective Hopkins returned, standing outside the truck to speak to Gittens through the

open window. Hopkins questioned Gittens about a firearm located during the search of Gittens’s

residence, and Gittens admitted to the possession of the firearm. Hopkins did not remind Gittens

of his Miranda rights or ask any questions about his prior statement that he was not willing to

speak.

Before trial, Gittens filed a motion to suppress, arguing that Hopkins improperly

questioned him about the firearm after Gittens had invoked his Fifth Amendment right to remain

silent. He asked the court to suppress all statements made after he invoked that right. The

Commonwealth responded that Gittens did not unambiguously invoke the right to remain silent,

arguing that he only expressed reservations about being seen cooperating with law enforcement.

At the suppression hearing, Gittens asserted that he invoked his right to silence by

answering “No” when Hopkins asked whether Gittens wanted to talk right now. He also argued

that Hopkins should have reread him his Miranda rights before questioning him again. Rather

-3- than an unequivocal invocation, the Commonwealth argued Gittens engaged in “a lot of

hemming and hawing.” It also argued that Gittens initiated the conversation with Joy and thus

he “willingly and voluntarily” reinitiated the conversation and waived his invocation of the right

to remain silent. Gittens responded that his remarks to Joy were just generalities and that

Hopkins did not know that Gittens had reinitiated conversation with Joy.

The trial court found that Gittens invoked his right to remain silent when he said “No” in

response to Hopkins’s question about his willingness to speak right now. It found that during the

conversation with Joy, Gittens was “not talking about the facts of the investigation as far as

what’s going on and his role in that investigation.” Therefore, the trial court granted the motion

to suppress the incriminating statements. The Commonwealth now appeals.

II. ANALYSIS

In reviewing the trial court’s ruling on a motion to suppress, “[w]e are bound by the trial

court’s findings of historical fact unless ‘plainly wrong’ or without evidence to support them.”

McCracken v. Commonwealth, 39 Va. App. 254, 258 (2002) (en banc) (quoting McGee v.

Commonwealth, 25 Va. App. 193, 198 (1997) (en banc)). Though we review de novo the

application of the law to those facts. Jones v. Commonwealth, 71 Va. App. 375, 380 (2019).

The Fifth Amendment of the United States Constitution guarantees that “[N]o person . . .

shall be compelled in any criminal case to be a witness against himself.” U.S. Const. amend. V.

“Upon taking a suspect into custody, police are required to warn him of his right to an attorney

and the right to remain silent during questioning by police.” Thomas v. Commonwealth, 72

Va. App. 560, 574 (2020). “If the defendant indicates that he wishes to remain silent at any point

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
North Carolina v. Butler
441 U.S. 369 (Supreme Court, 1979)
Edwards v. Arizona
451 U.S. 477 (Supreme Court, 1981)
Oregon v. Bradshaw
462 U.S. 1039 (Supreme Court, 1983)
Knox v. Commonwealth
663 S.E.2d 525 (Court of Appeals of Virginia, 2008)
Medley v. Commonwealth
602 S.E.2d 411 (Court of Appeals of Virginia, 2004)
McCracken v. Commonwealth
572 S.E.2d 493 (Court of Appeals of Virginia, 2002)
McGee v. Commonwealth
487 S.E.2d 259 (Court of Appeals of Virginia, 1997)
Commonwealth v. Peterson
424 S.E.2d 722 (Court of Appeals of Virginia, 1992)
Harrison v. Commonwealth
423 S.E.2d 160 (Supreme Court of Virginia, 1992)

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